2012-03-07_PERMIT FILE - C2010088 (28)

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McClave Canyon Mine Expansion and Fruita Loadout Facility Biological Assessment produces an, enzyme that detoxifies the PAHs, but then generates more carcinogenic and mutagenic and carcinogenic by- products "(Campbell and Devlin, 1997). Coal could enter the water in Reed Wash, the 100 -year floodplain, and designated critical habitat for Colorado pikeminnows as fugitive dust .from the stockpile and transfer processes -at the Loadout Facility,':as fugitive dust from loaded coal cars, -and from released coal from bottom doors of loaded coal cars crossing Reed Wash. ZPA requires a Fugitive Coal Dust Emission Control -Plan (40 CFR •Chapter 1, Section 60.254) that incorporates one or more measures' -that will limit fugitive coal dust to the greatest extent practicable. Control measures permitted at the Loadout Facility by the CDPHE Air Pollution Control Div. ision (Permit.No. 10ME2000, page 6) include: 1. Emissions from material - handling (i.e: •.removal, .loading, and hauling) shall be - controlled - by use of partial enclosures and watering at all times unless- natural moisture is sufficient to, control emissions. 2. Unpaved.haul roads shall be graveled,-as per initial application, and watered as-often As needed to control fugitive particulate emissions such that the above guidelines are met. 3. Plant entryway and truck service roads shall be graveled or paved. Watering shall be implemented if emission guidelines above are not met. Wind- related loss of coal at, the Loadout Facility was modeled (Air Resource Specialists, -2010) to include hourly and annual emissions of particulates from various components at-the, Loadout Facility. Without control of fugitive dust, model - results indicate there would be 7.6 ' tons 'of fugitive PM30 (particulate matter, 410 pm) emitted per year by -the Loadout Facility. 'With emission controls -applied, total .fugitive PM1a emissions were estimated' at 4,8 tons per -year ;' a reduction of -37 percent.. Most fugitive emissions .would be' caused by coal dozing to maintain the coal stockpile (4:008 tons /year), coal hauling on haul roads (0.411 tons /year), and wind- generated fugitive coal dust-from the-stockpile (0.368 tons /year)--(Air -Resource Specialists, 2010). Annual deposition of fugitive coal dust In Reed Wash or the 100 -year floodplain was not estimated, although it would be minimized by the Fugitive Coal Dust Emission Control Plan. National Coal Trahsobdafio i Association.• ('NCTA, 2067), reported, results - of studies conducted by 13urlingt6ri- Nothem Santa Fe (BNSF) Railroad along the.Powder Rivet Basin Joint Line. Coat lost from coal cars in' transit was measures to.deterrriiO efficacy of treatments to ",reduce coal loss. bottom,loss'of coal from eapid'discharge' car-doors was, on average i9.pounds: per car for a 216 -mile trip. After adjusting rail car doors, there was a 32 percent decrease in bottom loss (NCTA, 2007). in addition, dust collectors were - attached to the tops of loaded.coal cars. During a 567-mile test run, 225 pounds of coal per: car were lost from the tops -of untreated'boal cars but only 52 pounds per bar were lost 'from coal sprayed with a dust suppression chemical. Coal could enter Reed Wash and the 1100 -year floodplain either escaping from bottom doors when loaded coal cars -are on.the' 120 -foot long open deck rail 6�idge'proposed.to span the creek and floodplain and /6r from fugitive coal dust in loaded cars on the bridge or in the vicinity. Because there will be approximately 50 unit coal trains per year with 100 to: 110' coal cars per unit train, -calculations with. sirriplifying 'assumptions (uniform loss of coal per - distance traveled) using the above data yields estimates of 10 to 11 pounds of coal 'per year entering the I OC) year floodplain from coal car bottom doors (unadjusted) and up to 50 pounds of fugitive coal dust (untreated) per year from car tops. Rail Berl and Bridge Construction. ' Reed Wash and the 100 -year floodplain would,be crossed by the railroad spur -on a -117 -foot long ;bridge. Construction of the spur would affect approximately 0.045 acre within the 100 -year floodplain on the west-bank of Reed-Wash and 0.048 acre on the east bank. Fractured hard rock from a nearby quarry would be used to build 24